April 20, 2015

Exemption No. 11402 Regulatory Docket No. FAA–2015–0149

Mr. Thomas Ryan Drake
28388 Maitland Lane Santa Clara, CA 91350

Dear Mr. Drake:

This letter is to inform you that we have gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated January 20, 2015, you petitioned the Federal Aviation Administration (FAA) for an exemption. The exemption would allow th e petitioner to operate an unmanned aircraft system (UAS) to conduct video filming and phot ography by air for public and private use and to inspect land for residential, commercial, and industrial struct ures and property.

See Appendix A for the petition submitted to the FAA describing the proposed operations and the regulations that the petitioner seeks an exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to the petitioner.

Airworthiness Certification

The UAS proposed by the petitione r is a DJI Phantom Vision 2+.2

In accordance with the statutory criteria provided in Section 333 of Public Law 112

− 95 in reference to 49 U.S.C. § 44704, and in consider ation of the size, weight, speed, and limited operating area associated with the aircraft a nd its operation, the Secret ary of Transportation
has determined that this airc raft meets the conditions of Section 333. Therefore, the FAA finds that the relief from 14 CFR part 21, Certification procedures for products and parts, Subpart H—Airworthiness Certificates , and any associated noise certification and testing requirements of part 36, is not necessary.

The Basis for Our Decision

You have requested to use a UAS for aerial da ta collection. The FAA has issued grants of exemption in circumstances similar in all materi al respects to those pr esented in your petition. In Grants of Exemption No s. 11062 to Astraeus Aerial ( see Docket No. FAA

− 2014

− 0352), 11109 to Clayco, Inc. ( see Docket No. FAA

− 2014

− 0507), 11112 to VDOS Global, LLC ( see Docket No. FAA

− 2014

− 0382), and 11213 to Aeryon Labs, Inc. ( see Docket No.
FAA

− 2014

− 0642), the FAA found that the enhanced safety achieved using an unmanned aircraft (UA) with the specifica tions described by the petition er and carrying no passengers or crew, rather than a manned aircraft of signi ficantly greater proporti ons, carrying crew in addition to flammable fuel, gi ves the FAA good cause to find th at the UAS operation enabled by this exemption is in the public interest.

Having reviewed your reasons for re questing an exemption, I find that—

 They are similar in all material respects to relief previously re quested in Grant of Exemption Nos. 11062, 11109, 11112, and 11213;

 The reasons stated by the FAA for granting Exemption Nos. 11062, 11109, 11112, and 11213 also apply to the situ ation you present; and

 A grant of exemption is in the public interest.

Our Decision

In consideration of the foregoing, I find that a gr ant of exemption is in the public interest. Therefore, pursuant to the authority contained in 49 U.S. C. 106(f), 40113, and 44701, delegated to me by the Administrator, Mr. Thom as Ryan Drake is granted an exemption from 14 CFR §§ 61.23(a) and (c), 61.101(e)(4) and (5), 61.113(a), 61.315(a), 91.7(a), 91.119(c), 91.121, 91.151(a)(1), 91.405(a), 91.407(a )(1), 91.409(a)(1) an d (2), and 91.417(a) and (b), to the extent necessary to allow the petitioner to operate a UAS to perform aerial data collection. This exemption is subject to the conditions and limitations listed below.

Conditions and Limitations

In this grant of exemption, Mr. Thomas Ryan Dr ake is hereafter referred to as the operator.3

Failure to comply with any of the conditions an d limitations of this grant of exemption will be grounds for the immediate suspension or rescission of this exemption.

1. Operations authorized by this grant of ex emption are limited to the DJI Phantom Vision 2+ when weighing less than 55 pounds includ ing payload. Proposed operations of any other aircraft will require a new petition or a petition to amend this exemption.

2. Operations for the purpose of closed-set motion picture and television filming are not permitted.

3. The UA may not be operated at a speed exceeding 87 knots (100 miles per hour). The exemption holder may use either groundspeed or calibrated airspeed to determine compliance with the 87 knot speed restricti on. In no case will the UA be operated at airspeeds greater than the maximum UA operating airspeed recommended by the
aircraft manufacturer.

4. The UA must be operated at an altitude of no more than 400 feet above ground level (AGL). Altitude must be reported in feet AGL.

5. The UA must be operated within visual line of sight (VLOS) of the PIC at all times. This requires the PIC to be able to use human vision unaided by any device other than corrective lenses, as specified on the PIC’s FAA-issued airman medical certificate or U.S. driver’s license.

6. All operations must utilize a visual observer (VO). The UA must be operated within the visual line of sight (VLOS) of the PIC a nd VO at all times. The VO may be used to satisfy the VLOS requirement as long as the PIC always maintains VLOS capability. The VO and PIC must be able to communicat e verbally at all times; electronic messaging or texting is not permitted duri ng flight operations. The PIC must be designated before the flight and cannot tran sfer his or her designation for the duration of the flight. The PIC must ensure that the VO can perform the du ties required of the
VO.

7. This exemption and all documents needed to operate the UAS and conduct its operations in accordance with the conditions and limitations stated in this grant of exemption, are hereinafter referred to as the operating documents. The operating documents must be accessible during UAS operations and made available to the Administrator upon request. If a discrepa ncy exists between the conditions and limitations in this exemption and the pro cedures outlined in the operating documents,
the conditions and limitations herein ta ke precedence and must be followed. Otherwise, the operator must follow the pr ocedures as outlined in its operating documents. The operator may update or revi se its operating documents. It is the operator’s responsibility to track such revisions and pr esent updated and revised documents to the Administrator or any la w enforcement official upon request. The4

operator must also present updated and revise d documents if it petitions for extension or amendment to this grant of exemption. If the operator determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the operator must petition for an amendment to its grant of exemption. The FAA’s UAS Integration Office (AFS

− 80) may be contacted if questi ons arise regarding updates or revisions to the operating documents.

8. Any UAS that has undergone maintenance or alterations that aff ect the UAS operation or flight characteristics, e .g. replacement of a flight cr itical component, must undergo a functional test flight prio r to conducting further opera tions under this exemption. Functional test flights may only be conducted by a PIC with a VO and must remain at least 500 feet from other people. The functi onal test flight must be conducted in such a manner so as to not pose an undue hazard to persons and property.

9. The operator is responsible for maintaining a nd inspecting the UAS to ensure that it is in a condition for safe operation.

10. Prior to each flight, the PIC must conduct a pre-flight inspection and determine the UAS is in a condition for safe flight. Th e pre-flight inspection must account for all potential discrepancies, e .g. inoperable components, items, or equipment. If the inspection reveals a condition that affects the safe operation of the UAS, the aircraft is prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight.

11. The operator must follow the UAS manu facturer’s maintenance, overhaul, replacement, inspection, and life limit requirements for the aircraft and aircraft components.

12. Each UAS operated under this exemption must comply with all manufacturer safety bulletins.

13. Under this grant of exemption, a PIC mu st hold either an airline transport, commercial, private, recreational, or sport pi lot certificate. The PIC must also hold a
current FAA airman medical certificate or a valid U.S. driver’s license issued by a state, the District of Colombia, Puerto Rico, a territory, a possession, or the Federal government. The PIC must also meet the flight review requirements specified in 14 CFR § 61.56 in an aircraft in which the PI C is rated on his or her pilot certificate.

14. The operator may not permit any PIC to ope rate unless the PIC demonstrates the ability to safely operate the UAS in a ma nner consistent with how the UAS will be operated under this exemption, including evasive and emergency maneuvers and maintaining appropriate distan ces from persons, vessels, vehi cles and structures. PIC qualification flight hours and currency must be logged in a manner consistent with 14 CFR § 61.51(b). Flights for the purposes of training the operator’s PICs and VOs5

(training, proficiency, and e xperience-building) and determining the PIC’s ability to safely operate the UAS in a manner consistent with how the UAS will be operated under this exemption are permitted under the terms of this exemption. However, training operations may only be conducted dur ing dedicated training sessions. During training, proficiency, and expe rience-building flights, al l persons not essential for flight operations are considered nonpartic ipants, and the PIC must operate the UA with appropriate distance from nonparti cipants in accordance with 14 CFR § 91.119.

15. UAS operations may not be conducted during night, as defined in 14 CFR § 1.1. All operations must be conducted under visual meteorological conditi ons (VMC). Flights under special visual flight rule s (SVFR) are not authorized.

16. The UA may not operate within 5 nautical mile s of an airport reference point (ARP) as denoted in the current FAA Airport/Facil ity Directory (AFD) or for airports not denoted with an ARP, the center of the airport symbol as denoted on the current FAA-published aeronautical chart, unless a letter of agreement with that airport’s management is obtained or otherwise permitted by a COA issued to the exemption holder. The letter of agreement with the ai rport management must be made available to the Administrator or any law enforcement official upon request.

17. The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

18. If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the pr ivate or controlled-access property.

19. The PIC must abort the flight in the even t of unpredicted obstacles or emergencies.

20. The PIC is prohibited from beginning a f light unless (considering wind and forecast weather conditions) there is enough available power for the UA to conduct the intended operation and to operate after that fo r at least five minutes or with the reserve power recommended by the manufacturer if greater.

21. Air Traffic Organization (ATO) Certificate of Waiver or Author ization (COA). All operations shall be conducted in accorda nce with an ATO-issued COA. The exemption holder may apply for a new or amended COA if it intends to conduct operations that cannot be conducted unde r the terms of the attached COA.

22. All aircraft operated in accord ance with this exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

− Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large as practicable.6

23. Documents used by the operator to ensure th e safe operation and flight of the UAS and any documents required under 14 CFR §§ 91.9 and 91.203 must be available to the PIC at the Ground Control Station of the UAS any time the aircraft is operating. These
documents must be made available to th e Administrator or any law enforcement official upon request.

24. The UA must remain clear and give wa y to all manned aviation operations and
activities at all times.

25. The UAS may not be operated by the PIC from any moving device or vehicle.

26. All Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently pr otect nonparticipating persons from the UA and/or debris in the event of an accident. The operator must ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating persons leave such protection and are within 500 feet of the UA, flight operations must cease immediately in a manner ensuring the safety of nonparticipating persons; and
b. The owner/controller of any vessels, vehicles or struct ures has granted permission for operating closer to those objects and the PIC has made a safety assessment of the risk of operating closer to those objects and determined that it does not present an undue hazard.

The PIC, VO, operator trainees or es sential persons are not considered nonparticipating persons under this exemption.

27. All operations shall be conducted over priv ate or controlled-access property with permission from the property owner/cont roller or authorized representative. Permission from property owner/controller or authorized representative will be obtained for each flight to be conducted.

28. Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA's UAS Integration Office (AFS

− 80) within 24 hours. Accidents must be reported to the National Transportation Sa fety Board (NTSB) per instructions contained on the NTSB Web site: www.ntsb.gov

.

If this exemption permits operations for th e purpose of closed-set motion picture and television filming and production, the following additional conditions and limitations apply.

29. The operator must have a motion picture and television operations manual (MPTOM)
as documented in this grant of exemption.7

30. At least 3 days before aerial filming, the operator of the UAS affected by this exemption must submit a written Plan of Activities to the local Flight Standards District Office (FSDO) with jurisdiction ove r the area of proposed filming. The 3-day notification may be waived w ith the concurrence of the FSDO. The plan of activities must include at least the following:

a. Dates and times for all flights;
b. Name and phone number of the operator for the UAS aerial filming conducted under this grant of exemption;

c. Name and phone number of the person res ponsible for the on-s cene operation of the UAS;
d. Make, model, and serial or N

− Number of UAS to be used;

e. Name and certificate number of UAS PI Cs involved in the aerial filming;
f. A statement that the operator has obtain ed permission from property owners
and/or local officials to conduct the filming production event; the list of those who gave permission must be made av ailable to the inspector upon request;

g. Signature of exemption holde r or representative; and
h. A description of the flight activity, includi ng maps or diagrams of any area, city, town, county, and/or state over which film ing will be conducted and the altitudes essential to accomplish the operation.

31. Flight operations may be conducted closer th an 500 feet from pa rticipating persons consenting to be involved and necessary for the filming production, as specified in the exemption holder’s MPTOM.

Unless otherwise specified in this grant of exemption, the UAS, the UAS PIC, and the UAS operations must comply with al l applicable parts of 14 CFR including, but not limited to, parts 45, 47, 61, and 91.8

This exemption terminates on April 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/ John S. Duncan Director, Flight St andards ServiceThomas	Ryan	Drake

– Section	333	Exemption	Petition

January	20 ,	2015

U.S.	Department	of	Transportation,	Docket	Operations West	Building	Ground	Floor,	Room	w12

- 140 1200	New	Jersey	Ave.,	SE	Washington,	DC	20590

Re:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	of	the	Federal	Aviation Regulations	f rom 14	C.F.R.	61.113(a)&(b); 91.7(a);	91.9(b)	(2); 91.109;119.121; 91.151(a);	91.405(a);	91.407(a)	(1);	91.409(a)	(2);	91.417(a)&(b)

Dear Sir	or	Madam :

I,	Thomas	Ryan	Drake,	am	writing	pursuant	to	the	FAA	Modernization	and	Reform	Act	of 2012	and	the	pro cedures	contained	within	14	C.F.R.	11,	to	request	that	I,	Thomas	Ryan Drake,	an	owner	and	operator	of	small	unmanned	aircraft,	be	exempted	from	the Federal	Aviation	Regulations	(“FARs”)	listed	below	so	that	I, Thomas	Ryan	Drake ,	may operate	a	small	ultra	l ight	weight	unmanned	aircraft	system	(“UAS”)	commercially	in airspace	regulated	by	the	Federal	Aviation	Administration	(“FAA”) located	in	Southern California	(specifically	in	Los	Angeles	and	Ventura	Counties) in	accordance	with FAA	UAS Regulations	&	Polici es

.

This	exemption request is	made	based	on	information	outlined	in	this	petition,	as	well as	the	accompanying	DJI Phantom	Vision	2+	Operators	Manual 1 and	Personal	Protocols
and	Controls 2 .	The	DJI	Phantom Vision 2+	UAS	was	selected	because	it	has	a	proven capability	for	controlled	flight	as	well	as	a	gyro	stabilized	flight	mode,	GPS	aided navigation,	a	compass,	blinking	LED’s	on	the	bottom,	a	failsafe	mode	for	returning home,	and	prop	guards.	These	devices	are	offered	for	general	sale	around	the	world	and
have	often	been	used	as	Model	Aircraft	in	the	USA. In	addition, I, Thomas	Ryan	Drake

, have flown	UAS’s	in	a	recreational	capacity	since	2013	and	have adopted safety protocols	and	controls to	avoid	and	prevent	public	hazard,	as	well	as	manned	aircraft
hazar ds/catastrophe.	This	will	act	to	further	safety	protocols	exclusive	to	lightweight UAS's	specific	to	video	and	photography	usage	as	I, Thomas	Ryan	Drake

, record	flight data	and	other	information	gained	through	permitted	flight	operations	to share	with	the FAA	through	any	required	FAA	reports	to	assist	with	future	protocol	and safety regulation.

I.	Contact	Information

Thomas	Ryan	Drake DBA	six6one	Development
28388	Maitland	Ln.

1 Appendix	A

– DJI	Phantom	2	Vision+	Operator’s	Manual

2 Appendix	B

– Personal	Protocols	and	Controls 2 Appendix	B

– Personal	Protocols	and	ControlsThomas	Ryan	Drake

– Section	333	Exemption	Petition

Santa	Clarita,	CA Mobile:	(661)	313

- 5858 Email:	drake@six6one.com

II.	Informat ion	regarding	the	Phantom	2	Vision+	UAS

Specifically,	the	UAS	is:

A n	ultra	lightweight battery	operated	4

- motor	rotorcraft	in	the	form	of	a	quadcopter that	takes	off	and	lands	vertically,	manuf actured	by	DJI,	Model	Phantom	2 Vision + ,	with the	following equipment:

• An	on

- board	flight	computer	with	GPS	navigation	and	location	ability	that receives	signals	for	flight	controls	from	a	ground

- based	transmitter/controller;

• An	integrated	on

- board	camera	capable	of	capturing	imagery	in	the	form	of	full color,	h igh	definition	still	photos	and	video;

• An	on

- board	telemetry	system	that	delivers	flight	data	from	the	on

- board	flight computer	to	the	on

- board	radio	transmitter	including	altitude	AGL,	horizontal and	vertical	speed,	compass	direction	of	flight	and	direct ion	back	to	its	launch site;

• A	600mW,	5.8GHz	on

- board	radio	transmitter	that	transmits	live	video	from	the

on

- board	camera	plus	all	the	flight	data	from	the	telemetry	system	described above;

The	Ground	Station	Includes:

• A	Pilot	in	Command	(PIC)	in	oper ational	control	of	a	flight	operation	from beginning	to	end	and	who	controls	the	UAS	while	in	the	air;

• A	100mW,	2.4GHz	radio	transmitter/controller	operated	by	the	PIC	to	control the	UAS	while	in	flight;

• A	radio	receiver	receiving	live	video	and	flight	d ata	from	the	on

- board	camera and	computer	projects	it	all	together	onto	a	screen	for	the	PIC	to	view	during flight;

• A	Visual	Observer	(VO)	is	a	person	who	provides	a	second	pair	of	eyes	to	visually track	the	UAS	while	in	flight.

III. Proposed	Operations

I,	Thomas	Ryan	Drake,	intend to	use	UAS s in two areas.	First, I	seek an	exemption	to perform	video	filming	and	photographing	by	air	for	public	and	private	use

. Second, I will employ	UAS’s	to	inspect	land,	residential	commercial	and	indu strial	structures and
property.Thomas	Ryan	Drake

– Section	333	Exemption	Petition

Specifically, I will	use	UASs which	are	equipped	with	cameras	and	sensors,	in	order	to engage	in	the	following	commercial	activities in	Los	Angeles	and	Ventura	Counties :

(a)	Video	filming	by	air	and	photographing	for public	and private	pu rposes, including:	television,	cinematography, advertising	or promotio ns. Filming	and Photography	will	only	be	conducted	with	permission	and	under	contract	with registered	owners	or	with	any	local	government	author ity	and only when	safe	to
do	so.

(b)	Vide o	filming	by	air	and	photographing	to	support	professional	operations	in engineering,	land	surveying and	development ,	architecture,	real	estate	and other	related	professional	activities. Filming	and	Photography	will	only	be conducted	with	permission	and	un der	contract	with	registered	owners	or	with any	local	government	authority	and only when	safe	to	do	so.

(c)	Inspection by	air	of	infrastructure	such	as	bridges,	highways,	photovoltaic power	stations, and	pipelines .	These	inspections	will	only	be	done	unde r

contract and	permission with any	registered owners	or	with any	local government	authority	and only when	safe	to	do	so.

(d )	Inspection	by	air	of	land	and	residential,	commercial	and	industrial structures,	only	under	contract and	permission with any regis tered owners	or with any	local	government	authority	and only when	safe	to	do	so.

(e )	Support	provided	to	search	and	rescue	operations	and	reconnaissance	in cases	of	need,	emergency	or	natural	disasters	only	when	government	authorities have	reques ted	it	by contract	or	donation	and only when	safe	to	do	so.

IV. Relevant	Statutory	Authority

This	Petition	for	Exemption	is	submitted	pursuant	to	Section	333(a)	through	(c)	of	the FAA	Modernization	and	Reform	Act	of	2012	("Reform	Act").	Congress	has	directed	the FAA	"to	safely	accelerate	the	integration	of	civil	unmanned	aircraft	systems	into	the national	airspace	system."	Pursuant	to	Section	333	of	the	Reform	Act,	the	FAA Administrator	is	to	permit	unmanned	aircraft	systems	to	operate	in	the	National	Air Space	( "NAS")	where	it	is	safe	to	do	so	based	on	the	following	considerations:

• The	UAS’s	size,	weight,	speed	and	operational	capability;

• Operation	of	the	UAS	in	close	proximity	to	ai rports	and	populated	areas;	and

• Operation	of	the	UAS	within	the	visual	line	of sight	of	the	operator.

Additionally,	the	FAA	Administrator	has	general	authority	to	grant	exemptions	from	the agency's	safety	regulations	and	minimum	standards	when	the	Administrator	decides	a requested	exemption	is	in	the	public	interest.	See	49	U.S.C. §	106(f)	(defining	theThomas	Ryan	Drake

– Section	333	Exemption	Petition

authority	of	the	Administrator);	49	U.S.C.	§	44701(f)	(permitting	exemptions	from§§ 44701(a),	(b)	and§§	44702

- 44716,et	seq.).	A	party	requesting	an	exemption	must explain	the	reasons	why	the	exemption:	(1)	would	benefit	the	public	a s	a	whole,	and	(2) would	not	adversely	affect	safety	(or	how	it	would	provide	a	level	of	safety	at	least equal	to	the	existing	rules).	See	14	C.F.R.	§	1 1.81	(petitions	for	exemption).

V. These Proposed	UAS	Operations	Meet	the	Requirements	of	Section	333	o f	the
Reform	Act

The proposed	operations	in	this	Petition	for	Exemption	qualify	for	expedited	approval pursuant	to	Section	333	of	the	Reform	Act	as	each	of	the	statutory	criteria	and	relevant
factors	are	satisfied.

VI. Approval	is	Warranted	Based	on	th e	UAS	Size,	Weight,	Speed,	and	Operational Capability

I,	Thomas,	Ryan	Drake, will	employ	the	DJI	Phantom Vision 2 +	quadcopter for	the operations	specified	in	this	Petition	for	exemption.

• The Phantom	2	Vision+ UASs	have	a	maximu m	take

- off	weight	of	less than	5 pounds

• F light	speed	will	not	exceed	15 miles	per	hour,	and	it	will	not	be	flown	in controlled	airspace	or	at	an altitude	that	exceeds	3 00	feet	AGL.

• All	flights	will	be	flown	in	such	a manner that	they	can	be	safely	terminated	with
a	reserve	batter y	power	of no	less	than 20 %	of	the	battery's	maximum	charge.

• The	DJI Phantom	2	Vision+ UAS	do es not	carry	any	flammable	propellant	or	fuel.

• The Phantom	2	Vision+ UAS	has	an	integrated	GPS	system	that	calculates	the UAS’s	position	and	height	and	relays	th at	information	via	a	secure	connection	to the	operator.

• T he	Phantom	2 Vision+ UAS	contain	a	failsafe	mode	if	its	connection	to	the remote	control	is	lost,	and	this	system	permits	the	UAS	to	return	to	a predetermined	location	and land	without	injury	or	dam age.

• For	additional	safety,	the Phantom	2	Vision+ will	be	retrofitted	with	prop	guards.

VII. Approval	is	Warranted	Based	on	the	Operational	Restrictions	Set	Forth	in	the Operations	Manual.

DJI's	operators	manual 3 and	the Personal	Protocols	and	Controls 4 contain	all	of	the procedures	and	limitations	necessary	to	successfully	perform	the	operations	specified	in this	Petition	for	Exemption.

3 Appendix	A

4 Appendix	BThomas	Ryan	Drake

– Section	333	Exemption	Petition

VIII.	Public	Interest

The	public	interest	will	be	served	by	granting Thomas	Ryan	Drake	a Petition	for Exemption in Los	Angeles	and	Ventura	Counties .	Congress	has	established	a	national policy	that	favors	early	integration	of	UASs	into	the	NAS	in	controlled,	safe	working environments	such	as	those	proposed	in	this	Petition.	In	addition,	the	public	also	has	an

interest in	reducing	the	hazards	associated	with	alternate	methods	of	conducting	similar operations.	Currently	operations	are	conducted	using	teams	that	physically	climb	onto structures	using	ladders,	using	low	flying	helicopters	or	aircraft, are	extremely	cost

pr o hibitive or are simply	not	available	by	traditional	means.	By	using	UAS,	exposure	to phy sical	hazards	will	be	reduced	by conducting	the	operation	while	remaining	safely	on the	ground.

Additionally, the intended	uses of	the Phantom	2	Vision+ UAS	as outlin ed	in	this
document have	identifiable	safety	benefits	that	include	reducing	the	danger	and

emissions	associ ated	with	full	size	helicopters. UAS	have	no	fuel	to ignite	or	explode,	no crew,	add a	greater	degree	of	flexibility, supplement the	current	capabili ties	offered	by manned	aircraft,	and	public	interest	for	a	ground	impact	of	a	small	lightweight	UAS	is further	minimized	from	an	ecological	and	safety	standpoint.

I X .	A Summary The	FAA	May	Publish	in	the	Federal	Register :

A.	14	C.F.R.	91:	Airworthiness Certificates,	Manuals	and	The	Like.

14	C.F.R.	91.7(a) I,	Thomas	Ryan	Drake,	will	ensure	the UAS is	in	airworthy condition	based	on	compliance	with	the Phantom	2	Vision+ operating documents	prior	to	each	flight.

14	C.F.R.	§	91.121 Relief	is	requested	cons idering	the	limited	altitude	of proposed	operations

.

B .	14	C.F.R.	§	61.113:	Private	Pilot	Privileges	and	Limitations:	PIC.

Pursuant	to	14	C.F.R.	§ 61.113	(a), The	FAA	has	previously	declared	that additional	manned	airship	experience	of	a	commercially	cer tified	pilot	would	not
correlate	to	the airmanship skills	necessary	for	similarly	proposed	operations	in previously	issued	exemptions	to	this	regulation	through Exemption Nos.	11062
and	11138.

Pursuant	to	14	C.F.R.	§	61.113	(b), T he	stick	and	rudder	contr ols	of	the	typical
aircraft	one	would	be	trained	on	to achieve a	private	pilots	license	are completely	different	than	that	of	a	small	UAS .	Additionally

, the	FAA does	not require manned	ultra light	vehicle	PICs to	meet	any	aeronautical	knowledge,	age,

or	exp erience	requirements	or	to	have	airman	or	medical	cert ificates ( asThomas	Ryan	Drake

– Section	333	Exemption	Petition

outlined	in	14	C.F.R.	§	103)

. Ultralight	vehicles can weigh	more	than	500	pounds than	the	Phantom	2	Vision+, can carry up	to	5	gallons	of combustible	fuel,	and	fly at	speeds close	to double that ca pable	by	the	Phantom	2	Vision+. Due	to	these
facts

, and	in	the	absence	of	a	specific	UAS	Pilot	License

, I	submit	that prior	to any commercial operations	I,	Thomas	Ryan	Drake,	will obtain	a	Student	Pilot
Certificate	and complete a	basic	aviation	int roduction	course

, with 45 minutes	of logged	flight	time

, applied by	a	certified	flight	instructor

. I n	addition I	submit	32 plus	hours	of UAS	logged	flight	time	I	have	acquired	over	the	past	two	years 5

.

D.	14	C.F.R.	91.119 (c) :	Minimum	Safe	Altitudes.

14 C.F.R.	§	91.119 (c)	I,	Thomas	Ryan	Drake,	will	ensure	that	all	persons	and objects	not	essential	to	flight	operations	must	remain	500	feet	away	from operations.	In	addition	to	visual	monitoring	of	the	area,	a traffic cone	and warning sign 6 alerting	persons in	the	area	will	be	placed	at	the	operation	ground station.	To	protect	objects	and	personnel	essential	to	flight	operations	the Phantom	2	Vision+	will	be	fitted	with	propeller	guards	and	safety	wire 7 to minimize	potential	hazards.

E.	14	C.F.R.	91.151	(c) : Fuel	Requirements	for	Flight	in	VFR	Conditions

.

14	C.F.R.	91.151	(c), I,	Thomas	Ryan	Drake,	will	ensure	that	each	individual	flight will	not	begin	unless	there	is	enough	power	to	fly	to	the	first	point	of	intended landing	and	land	the	UA	with	30%	batter y	power	remaining.	In	addition,	each individual	flight	will	last	no	longer	than	20	minutes,	5	minutes	less	than	the manufacturer	stated	25	minutes	of	flight	time.

F .	14	C.F.R.	91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections.

T he	above

- cited	Regulations	require,	amongst	other	things,	aircraft	owners	and operators	to	“have	[the]	aircraft	inspected	as	prescribed	in	subpart	E	of	this	part
and shall	between	required	inspections,	except	as	provided	in	paragraph	(c)	of this	section, h ave	discrepancies	repaired	as	prescribed	in	part	43	of	this	chapter.
.	.	.”

These	Regulations	only	apply	to	aircraft	with	an	airworthiness	certificate.	They	will	not, therefore,	apply	to	my, Thomas	Ryan	Drake’s ,	UAS.	However,	as	a	safety	precaution	I

ins pect	my UAS per	operating	documents before	and	after	each	flight.

5 Appendi x	C

– Drake	UAS Flight	Logs

6 Appendix	D

– Warning	Sign

7 Appendix	E

– Phantom	2	Prop	Guard	Attachment	InstructionsThomas	Ryan	Drake

– Section	333	Exemption	Petition

X. Conclusion

This Petition	for	Exemption	satisfies	the	criteria	articulated	in	Section 333	of	the	Reform	Act	of	2012	including	weight,	speed,	operat ing	capabilities,	proximity

to airp orts	and	populated	areas,	operation	within	visual	line	of	sight	and	national security.	Additionally,	the	Petition	provides	more	than	adequate	justification	for	the grant	of	the	requested	exemptions	to	permit Thomas	Ryan	Drake	to	operate	a	Phantom

Vision	2+ Plus	UAS in	Los	Angeles	and	Ventura	Counties for	the	operations	specified
herein.

Granting	the	exemption	will	benefit	the	public	interest	as	a	whole	in	several	ways, including	(1)	significantly	improving	safety	and	reducing	risk	by	alleviating	human

exp osure	to	danger,	and	(2)	improving	the	quality	of	services	and	decreasing	operating costs	compared	with	conventional	flight	operations.

Very	Respectfully, Thomas	Ryan	Drake
28388	Maitland	Ln. Santa	Clarita,	CA	91350 drake@six6one.com